Privacy Policy

1. Scope and Application

This Privacy Policy ("Policy") applies to all personal data processed by rosa87 (hereinafter "the Platform", "we", "us", or "our") in connection with the operation of the website rosa87.cam and all associated services, mobile interfaces, live-chat systems, payment integrations, and communications channels. It applies to all persons who interact with rosa87 regardless of whether they have registered an account, including visitors, prospective users, registered players, VIP members, and former account holders.

This Policy is intended to satisfy the disclosure obligations imposed by Indonesian data-protection legislation, including the provisions of Government Regulation No. 71 of 2019 on Electronic System and Transaction Implementation (PP PSTE) and Law No. 27 of 2022 on Personal Data Protection (UU PDP), as well as internationally recognised standards such as the General Data Protection Regulation (GDPR) of the European Union, which we adopt as a benchmark for best practice even where not directly applicable.

By accessing or using rosa87 you confirm that you have read, understood, and agreed to this Policy. If you do not accept the terms set out herein, you must discontinue use of the Platform immediately.

2. Definitions

For the purposes of this Policy, the following terms shall have the meanings assigned below:

• "Personal Data" — any information relating to an identified or identifiable natural person ("Data Subject"), including name, identification number, location data, online identifiers, or factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person.
• "Processing" — any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, erasure, or destruction.
• "Data Controller" — rosa87, the entity that determines the purposes and means of processing Personal Data.
• "Data Processor" — a third party that processes Personal Data on behalf of rosa87 under a written agreement.
• "Consent" — freely given, specific, informed, and unambiguous indication of a Data Subject's agreement to the processing of their Personal Data.
• "Platform" — the rosa87 website at rosa87.cam, including all subdomains, applications, and associated services.
• "User" or "Player" — any natural person who accesses or uses the Platform, whether registered or not.
• "KYC" (Know Your Customer) — identity and document verification procedures required under applicable regulations and our internal compliance framework.

3. Information We Collect

3.1 Information You Provide Directly

When you interact with rosa87, you may provide us with the following categories of Personal Data:

• Identity Data: Full legal name, date of birth, gender, nationality, and government-issued identification number (KTP number, passport number, or driver's licence number).
• Contact Data: Email address, mobile phone number, and residential address including city (e.g., Jakarta, Surabaya, Medan, Bandung, Bali) and postal code.
• Account Data: Username, password (stored in hashed, encrypted form — never in plain text), security questions, and account preferences.
• Financial Data: Bank account details for Indonesian banks including BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, and Bank Permata; e-wallet identifiers for OVO, DANA, GoPay, ShopeePay, and LinkAja; transaction history; deposit and withdrawal records.
• KYC Documentation: Copies of government-issued identification documents, proof-of-address documents, selfie photographs, and source-of-funds declarations.
• Communications Data: Records of your interactions with our customer support team via live chat, email, and WhatsApp, including the content of those communications.
• Responsible Gaming Data: Self-exclusion requests, deposit limits, loss limits, session time limits, and responses to self-assessment questionnaires.

3.2 Information We Collect Automatically

When you visit or use the Platform, we automatically collect certain technical and behavioural data:

• Device and Technical Data: IP address, device type, operating system, browser type and version, screen resolution, time-zone setting, and language preferences.
• Usage Data: Pages visited, features used, games played, bet amounts and outcomes, session duration, click patterns, and navigation paths within the Platform.
• Location Data: Approximate geographic location derived from your IP address. We do not collect precise GPS coordinates unless you explicitly grant permission.
• Log Data: Server logs recording access timestamps, error reports, and system performance metrics.

3.3 Information from Third Parties

We may receive Personal Data about you from third-party sources, including:

• Payment processors and banking partners in connection with transaction verification and fraud prevention.
• Identity verification and KYC service providers who assist us in confirming the accuracy of documentation you submit.
• Analytics providers and advertising networks (where applicable) that help us understand aggregate user behaviour.
• Fraud-prevention and anti-money-laundering (AML) databases used to screen transactions and account registrations.

4. How We Collect Your Information

rosa87 collects Personal Data through the following mechanisms:

• Account Registration: Information you submit when creating your rosa87 account.
• Deposits and Withdrawals: Transaction details passed to us by your bank or e-wallet provider when you fund or withdraw from your account.
• KYC Submission: Documents you upload through the Platform's secure verification portal.
• Customer Support Interactions: Conversations you initiate via live chat, email, or other supported channels.
• Cookies and Tracking Technologies: Automated data collection via browser cookies, web beacons, pixel tags, and similar technologies as described in Section 7.
• Promotional Participation: Information you provide when claiming bonuses, entering tournaments, or responding to surveys.

5. Purposes and Legal Basis for Processing

rosa87 processes your Personal Data only where we have a lawful basis to do so. The table below sets out the purposes for which we process data and the corresponding legal basis under applicable data-protection law:

Where we rely on your consent as the legal basis for processing, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. To withdraw consent, contact us at [email protected] or adjust your communication preferences within your account settings.

6. Sharing and Disclosure of Information

rosa87 does not sell, rent, or trade your Personal Data to third parties for their own commercial purposes. We may, however, share your data with carefully selected third parties in the following circumstances:

6.1 Service Providers and Data Processors

We engage trusted third-party vendors who process data on our behalf under binding data-processing agreements. These include:

• Payment processing partners and banking intermediaries facilitating transactions with Indonesian banks (BCA, BRI, BNI, Mandiri, CIMB Niaga) and e-wallets (OVO, DANA, GoPay, ShopeePay, LinkAja).
• KYC and identity verification technology providers.
• Cloud hosting and infrastructure providers operating secure data centres.
• Customer relationship management (CRM) and live-chat software providers.
• Fraud prevention and anti-money-laundering screening services.
• Game content providers including Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, and Pocket Games Soft, where game-session data is necessary to deliver services.

6.2 Legal and Regulatory Disclosure

We may disclose Personal Data to competent authorities, regulators, law enforcement agencies, or courts when required to do so by applicable Indonesian law or international legal instruments, including but not limited to disclosures required by court order, subpoena, or regulatory investigation. In such cases, we will disclose only the minimum information necessary to satisfy the legal requirement.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of rosa87's business assets, Personal Data held by us may be transferred to the acquiring entity as part of that transaction. We will notify affected users by email or prominent Platform notice before data is transferred and becomes subject to a different privacy policy.

6.4 Aggregate and Anonymised Data

We may share aggregated, anonymised, or de-identified data that cannot reasonably be used to identify you with third parties for research, analytics, marketing, and business-intelligence purposes. Such data is not Personal Data and is not subject to the protections described in this Policy.

7. Cookies and Tracking Technologies

rosa87 uses cookies and similar tracking technologies to enhance your experience on the Platform, ensure security, and analyse usage patterns. A cookie is a small text file stored on your device by your browser at the request of a website.

7.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Platform to function correctly, including session management, authentication, and security tokens. These cannot be disabled without impairing Platform functionality.
• Performance and Analytics Cookies: Collect information about how visitors use the Platform — pages visited, time spent, error messages encountered — to help us improve performance and user experience.
• Functionality Cookies: Remember your preferences such as language settings, preferred game categories, and display options so we can deliver a more personalised experience.
• Targeting and Advertising Cookies: Used to deliver promotional content and offers relevant to your interests, both on and off the Platform. These are only placed where you have provided consent.

7.2 Managing Cookies

You may control and manage cookies through your browser settings. Most browsers allow you to refuse new cookies, delete existing cookies, or receive a warning before a cookie is stored. Please note that disabling certain cookies may affect the functionality of the Platform and your ability to access some features. Detailed instructions for managing cookies in popular browsers are available on the respective browser's support pages.

8. Data Retention

rosa87 retains Personal Data only for as long as necessary to fulfil the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce agreements. Our standard retention periods are as follows:

• Account Data: Retained for the duration of your account and for a minimum of 5 years following account closure, in accordance with AML record-keeping requirements under Indonesian law.
• Transaction and Financial Records: Retained for a minimum of 7 years from the date of the transaction, as required by Indonesian financial regulations.
• KYC Documentation: Retained for at least 5 years after the end of the business relationship or the date on which the transaction was completed, whichever is later.
• Customer Support Records: Retained for 2 years from the date of the last interaction, unless longer retention is required for an ongoing dispute or investigation.
• Marketing Preferences: Retained until you withdraw consent or opt out of marketing communications.
• Technical Log Data: Retained for up to 12 months for security and diagnostic purposes.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised so that it can no longer be associated with any identifiable individual.

9. Data Security

rosa87 implements a comprehensive set of technical, administrative, and physical security measures to protect your Personal Data against unauthorised access, disclosure, alteration, or destruction. Our security infrastructure includes:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and our servers is encrypted using industry-standard Transport Layer Security (TLS) protocols.
• Encrypted Data Storage: Sensitive data including passwords, financial identifiers, and KYC documentation is stored in encrypted form using AES-256 encryption at rest.
• Access Controls: Strict role-based access controls ensure that only authorised personnel can access Personal Data on a need-to-know basis. All internal access is logged and audited.
• Two-Factor Authentication (2FA): Available for all player accounts and mandatory for administrative access to internal systems.
• Regular Security Audits: We conduct periodic penetration testing, vulnerability assessments, and code reviews conducted by independent cybersecurity firms.
• Incident Response Plan: We maintain a documented data-breach response procedure. In the event of a breach affecting your Personal Data, we will notify you and relevant authorities within the timeframes required by applicable law.
• Secure Payment Processing: Financial transactions are handled by PCI DSS-compliant payment processors. rosa87 does not store full card numbers or CVV codes on its systems.

10. Your Rights as a Data Subject

Under applicable data-protection legislation, you have the following rights with respect to your Personal Data held by rosa87. We will respond to all verified requests within 30 calendar days. Complex requests may require up to 60 days; we will notify you if an extension is necessary.

To exercise any of the rights listed above, please submit a written request to [email protected] with the subject line "Data Subject Request". We may need to verify your identity before processing the request to prevent unauthorised disclosure of Personal Data.

11. International Data Transfers

rosa87 primarily serves users in Indonesia and processes most data within the region. However, some of our third-party service providers, including cloud infrastructure and analytics partners, may process data in jurisdictions outside Indonesia. Where such transfers occur, we ensure that appropriate safeguards are in place, including:

• Standard contractual clauses approved by competent data-protection authorities.
• Data processing agreements requiring recipients to uphold protection standards equivalent to those required under Indonesian law and this Policy.
• Transfers to jurisdictions that have been assessed as providing an adequate level of data protection by relevant regulatory bodies.

By using the Platform, you acknowledge that your Personal Data may be transferred to and processed in countries other than Indonesia. We will always ensure such transfers are made in compliance with applicable law and with appropriate protections in place.

12. Third-Party Links and Services

The Platform may contain references or integrations involving third-party game studios (such as Pragmatic Play, Evolution Gaming, and Microgaming), payment providers (such as BCA, BRI, OVO, and DANA), and analytics tools. While we take care to work only with reputable partners, rosa87 is not responsible for the privacy practices of third parties.

We encourage you to review the privacy policies of any third-party services you interact with through the Platform. This Policy applies solely to data collected and processed by rosa87 directly.

13. Children's Privacy

rosa87 strictly prohibits use of the Platform by individuals under the age of 21. We do not knowingly collect Personal Data from anyone under 21 years of age. If we become aware that a minor has registered an account or submitted Personal Data, we will immediately close the account and delete all associated data. If you believe a minor has accessed our Platform, please notify us immediately at [email protected].

Age verification is a mandatory part of our KYC process, and we reserve the right to request proof of age at any stage of the registration or verification process.

14. Amendments to This Policy

rosa87 reserves the right to update or amend this Privacy Policy at any time. When we make material changes, we will update the "Last Updated" date at the top of this document and, where appropriate, notify registered users via email or a prominent notice on the Platform. We encourage you to review this Policy periodically to stay informed about how we protect your information.

Your continued use of the Platform after any amendments have been posted constitutes your acceptance of the revised Policy. If you do not agree with the changes, you must cease using the Platform and may request account closure by contacting our support team.

15. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of the Republic of Indonesia, including but not limited to Law No. 27 of 2022 on Personal Data Protection (UU PDP), Government Regulation No. 71 of 2019 on Electronic System and Transaction Implementation (PP PSTE), and Law No. 11 of 2008 on Electronic Information and Transactions (UU ITE) as amended. Any disputes arising from or in connection with this Policy shall be subject to the exclusive jurisdiction of the competent courts of Indonesia.

16. Contact and Data Requests

If you have any questions, concerns, or requests regarding this Privacy Policy or the way rosa87 handles your Personal Data, please contact our Data Protection team through the following channels:

• Email: [email protected]
• Subject Line for Data Requests: "Data Subject Request – [Your Full Name]"
• Live Chat: Available 24/7 through the Platform
• Response Time: We aim to acknowledge all privacy-related enquiries within 3 business days and provide a full response within 30 calendar days.

Our customer support team includes Indonesian-speaking agents available around the clock to assist you with any queries relating to your Personal Data or this Policy.